Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the portion of the court of appeals' judgment declaring that the rules issued by the Texas Board of Chiropractic Examiners authorizing chiropractors to perform an eye-movement test for neurological problems known as VONT, holding that the challenged rules do not exceed the statutory scope of the chiropractic practice.The Texas Chiropractic Act defines the practice of chiropractic to include evaluating the musculoskeletal system and improving the subluxation complex. In 2006, the Board adopted a rule defining both terms as involving nerves in addition to muscles and bones. In 2010, the Board adopted a rule authorizing chiropractors to perform vestibular-ocular-nystagmus testing, or VONT. The Texas Medical Association (TMA) challenged the rules in court. The court of appeals concluded that the rules exceeded the scope of practice prescribed in the Act. The Supreme Court reversed, holding that the challenged provisions are valid. View "Texas Board of Chiropractic Examiners v. Texas Medical Ass'n" on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that the trial court lacked jurisdiction over claims of a limited partner for harm done to the partnership because he lacked standing to bring the claims individually, holding that the appeal should be reconsidered in light of Pike v. Texas EMC Management, LLC, 610 S.W.3d 763 (Tex. 2020).Plaintiff formed multiple real estate-related partnerships and then sued his partners, later adding the partnerships as plaintiffs. Defendants filed a plea to the jurisdiction, asserting that Plaintiff individually lacked standing to bring claims against the individual individuals because the claims belonged to the partnerships. The trial court denied the plea. The court of appeals reversed and dismissed Plaintiff's individual claims for lack of jurisdiction, concluding that Defendant lacked standing to assert his original individual claims and that the doctrine of relation back could not create jurisdiction where none existed. The Supreme Court reversed, holding that the court of appeals' holding regarding standing was in direct conflict with Pike. View "Cooke v. Karlseng" on Justia Law

The Supreme Court conditionally granted relief to Mother on her petition for mandamus and directed the trial court to vacate its order holding Mother in contempt, holding that Mother was entitled to her requested relief.After a hearing, the trial court signed an enforcement order finding Mother in contempt of forty-eight violations of an agreed order the trial court entered upon the separation of Mother and Father. On appeal, Mother argued that the agreed order was too ambiguous to be enforced by contempt. The Supreme Court agreed and granted a writ of mandamus to Mother, holding that the agreed order could not support the contempt order because it did not "set forth the terms of compliance in clear, specific, and unambiguous terms." View "In re Pamela Janson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing a jury's finding that Jeffery Lee Stoddard was a sexually violent predator (SVP) and civilly committing him under Tex. Health & Safety Code chapter 841, holding that the court of appeals applied an improper standard.The court of appeals described the standard governing the factual sufficiency review in which the burden of proof was beyond a reasonable doubt the court of appeals described the standard as requiring the court to weigh the evidence in a neutral light to determined whether the jury's finding was factually insufficient or so against the great weight and preponderance as to be manifestly unjust, shock the conscience, or clearly demonstrate bias. The Supreme Court reversed, holding (1) the court of appeals applied an improper standard that allowed the court to substitute its own judgment for that of a reasonable fact-finder and incorporated a statutory element that chapter 841's text did not support; and (2) a properly conducted factual-sufficiency review in an SVP case requires the appellate court to determine whether, on the entire record, a reasonable factfinder could find beyond a reasonable doubt that the defendant is an SVP. View "In re Commitment of Jeffery Lee Stoddard" on Justia Law

The Supreme Court conditionally granted Alfred Brown's petition for writ of mandamus challenging the determination of the Comptroller of the State of Texas denying Brown's compensation claim brought after he was found to be wrongfully convicted and imprisoned, holding that Brown was eligible for compensation under the Time Cole Act. See Tex. Civ. Prac. & Rem. Code 103.001-.154.Brown was wrongfully convicted of capital murder and sentenced to death. After serving more than twelve years behind bars, Brown was released from prison when it was determined that the prosecuting attorney withheld and suppressed exculpatory evidence. After securing a judicial declaration of actual innocence Brown sought compensation under the Act for the time he was wrongfully imprisoned. The Comptroller denied the compensation claim, concluding that the district court had jurisdiction to issue an order declaring Brown actually innocent. The Supreme Court conditionally granted Brown's petition for writ of mandamus, holding (1) Brown was eligible for compensation under the Act; and (2) the Comptroller exceeded his authority by considering matters beyond the verified documents to make a de novo jurisdictional determination. View "In re Alfred Dewayne Brown" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and remanded Petitioner's factual sufficiency complaint for the court's consideration, holding that the court of appeals erred in finding that Petitioner failed to preserve its complaint about the factual sufficiency of the evidence.Respondent filed a breach of contract claim against Petitioner, and the jury awarded Respondent actual damages of $361,295. On appeal, Petitioner argued that the evidence was legally and factually insufficient to support the jury's verdict and that the trial court abused its discretion in admitting certain disposition testimony. The court of appeals held the evidence legally sufficient to support the trial court's judgment, concluded that the deposition testimony admission was not an abuse of discretion, and determined that the factually sufficiency complaint was inadequately briefed. The Supreme Court remanded the case, holding (1) the court of appeals did not err in sustaining the admission of the deposition testimony; but (2) the factual sufficiency issue was adequately briefed and argued and should have been considered. View "Lion Copolymer Holdings, LLC v. Lion Polymers, LLC" on Justia Law

In this dispute over the meaning of an oil and gas lease covering an 11,300-acre tract in Howard County, the Supreme Court reversed the judgment of the court of appeals affirming the trial court's grant of summary judgment for Energen Resources Corp. and John Quinn, holding that the contested provision of the lease in this case was ambiguous.The lease at issue allowed Endeavor Energy Resources, L.P. to retain its leasehold interest in the parcel only by drilling a new well every 150 days, with the exception that Endeavor could "accumulate unused days in any 150-day term...in order to extend the next allowed 150-day term between the completion of one well and the drilling of a subsequent well." At issue on appeal was how to calculate the number of "unused days." Energen and Quinn argued that the contested provision unambiguously allowed unused days earned in any term to be carried forward only once to the next 150-day term. The trial court agreed, and the court of appeals affirmed. The Supreme Court reversed, holding that the disputed provision was ambiguous. View "Endeavor Energy Resources, LP v. Energen Resources Corp." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying the plea to the jurisdiction filed by Defendant, a governmental employer, and dismissed Plaintiff's age-discrimination claim for lack of jurisdiction, holding that the Texas Commission on Human Rights Act did not waive Defendant's sovereign immunity from this suit.Plaintiff sued for age discrimination. Defendant filed a plea to the jurisdiction. The trial court denied the plea, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiff failed to submit legally sufficient evidence to establish a prima facie case of discrimination; and (2) because the legislature has not waived governmental immunity in the absence of such evidence, Plaintiff's age-discrimination claim must be dismissed for lack of jurisdiction. View "Texas Tech University Health Sciences Center-El Paso v. Flores" on Justia Law

In this negligence action, the Supreme Court vacated the default judgment entered by the trial court in favor of Plaintiff after Defendants failed timely to file an answer or otherwise appear, holding that the substitute service in this case did not strictly comply with the order permitting such service.More than thirty days after the trial court's default judgment entry, Defendants filed a restricted appeal asserting that Plaintiff had failed properly to serve them with process. The court of appeals affirmed, holding that a discrepancy between the address at which the trial court authorized substitute service and the address where the process server actually sent substitute service did not invalidate service or the default judgment. The Supreme Court vacated the default judgment, holding that substitute service did not strictly comply with the trial court's order. View "Spanton v. Bellah" on Justia Law

In this personal injury case, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part the trial court's summary judgments in favor of an electric utility and its independent contractor, holding that fact issues precluded summary judgment in favor of the contractor.Plaintiff sued the utility and its contractor (collectively, Defendants) for negligence, negligence per se, and gross negligence. The trial court granted summary judgment for Defendants. The court of appeals reversed the summary judgment as to the negligence claim against the independent contractor and as to all claims against the utility and remanded for further proceedings. The Supreme Court affirmed in part and reversed in part, holding (1) a genuine issue of material fact existed as to whether the contractor breached a duty of care; but (2) because the utility owed no duty with respect to the independent contractor's work, the court of appeals erred in reversing summary judgment as to Plaintiff's claims against the utility. View "AEP Texas Central Co. v. Arredondo" on Justia Law